No, you cannot say it is "free", unless ...
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https://www.ftc.gov/system/files/ftc_gov/pdf/d09408_commission_final_order.pdf
The FTC’s final order, issued January 19th, bars Intuit from saying that any of its goods or services are free unless it’s free for all customers or unless the company clearly displays which percentage of consumers qualify or discloses that a majority of consumers aren’t actually eligible. Now, the TurboTax website says roughly 37 percent of filers qualify for its “free” basic tier of tax filing assistance.
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“The order also sends a message across industry – ‘free’ means free – not ‘free for a few’ or ‘free for some,’” Samuel Levine, director of the FTC’s Bureau of Consumer Protection, said in a statement yesterday.